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CERT-In SBOM Guidelines: How to Achieve Compliance

By OPSWAT
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CERT-In (the Indian Computer Emergency Response Team), under MeitY (the Ministry of Electronics and Information Technology), has been steadily expanding its role as the national authority for cybersecurity since its designation under the Information Technology Amendment Act of 2008.

In 2024, CERT-In issued its first dedicated guidelines on SBOM (Software Bill of Materials), defining minimum elements, formats, and implementation requirements.

Just a year later, in July 2025, version 2.0 significantly broadened the scope, extending coverage to SBOM, QBOM, CBOM, AIBOM, and HBOM, further establishing secure software supply chains as a core national resilience strategy.

For CIOs and CISOs, these guidelines carry operational, financial, and regulatory consequences. Organizations must be ready to demonstrate audit-ready SBOM practices, align vendors and partners with compliance requirements, and adopt automation to manage SBOMs at scale.

This article delivers a step-by-step roadmap to achieving CERT-In SBOM guidelines compliance, covering scope, technical standards, vendor selection, and best practices for Indian enterprises and global organizations with operations in India.

CERT-In SBOM Guidelines: Scope, Applicability, and Key Requirements

What Is CERT-In and Why Has It Issued SBOM Guidelines? 

CERT-In is India’s national cybersecurity agency. Its SBOM guidelines aim to strengthen supply chain security, improve visibility into software components, and ensure faster, standardized responses to vulnerabilities.

What Is CERT-In and Why Has It Issued SBOM Guidelines?

Compliance applies to government, public sector, essential services, and software exporters, as well as developers, integrators, and resellers across the software lifecycle.

Core Elements of an SBOM as Per CERT-In Guidelines

According to the guidelines, SBOMs must include data such as:

  • Component name, version, supplier, and license
  • Dependencies and origin
  • Vulnerabilities and patch status
  • End-of-life dates, usage restrictions, and criticality
  • Unique identifiers, checksums, and author information

By requiring these minimum elements, CERT-In ensures that SBOMs are actionable, machine-readable, and ready for audit.

How OPSWAT SBOM Helps With CERT-In Requirements

OPSWAT SBOM helps with the automation and collection of CERT-In SBOM data fields, to provide visibility and transparency across the main areas, from software component details, transparency & risks, and licensing & usage.

Software Component Details

  • Component Name: Name of the software component or library.
  • Component Version: Version number or identifier of the component.
  • Component Supplier: Entity providing the component (vendor, third-party, or open-source).
  • Component Origin: Source of the component (proprietary, open-source, or third-party).
  • Unique Identifier: Distinct code for tracking the component across versions and ownership.
  • Author of SBOM Data: Entity responsible for creating the SBOM entry.
  • Timestamp: Date and time the SBOM entry was recorded.

Software Transparency & Risks

  • Component Dependencies: Other components or libraries this one relies on.
  • Vulnerabilities: Known security issues tied to the component, with severity and CVE references.
  • Patch Status: Current update or patch availability for vulnerabilities.
  • Checksums or Hashes: Cryptographic values to verify file integrity.
  • Executable Property: Whether the component can be executed.
  • Archive Property: Whether the component is packaged as an archive file.
  • Release Date: Date the component was first released.

Licensing & Usage

  • Component License: License type and terms governing the component’s use.
  • Usage Restrictions: Legal or regulatory limitations on component use.

Aligning Software Components with CERT-In SBOM Compliance

Achieving CERT-In compliance is a phased journey that requires coordination across development, security, operations, and compliance teams. Each stakeholder plays a role in creating, maintaining, and sharing SBOMs at different points in the software lifecycle.

The table below, containing content and examples from the CERT-In Technical Guidelines, illustrates how SBOM responsibilities align with common software components:

Component/SoftwareSBOM LevelSBOM Authorなぜですか?
Main ApplicationA data analyzer applicationApplication-level SBOMCreated by the product development teamComplete SBOM delivered with the application to the customer or regulator
Key Software Component [database, framework]PostgreSQLTop-level SBOMDeveloped internally if vendor did not provide a SBOMEnsures traceability of critical components
Platform/Middleware [e.g., web server, runtime environment]Apache Tomcat ServerDelivery SBOMProvided by the platform/vendorShared upon procurement; integrates vendor-provided components
Third-party libraries/SDKsPostfix & Twilio SDKTransitive SBOMCreated by upstream provider or internally if unavailableCovers indirect dependencies and external services

With roles and responsibilities defined, organizations can move into the practical steps of compliance. A phased roadmap helps build maturity across people, processes, and technology.

1. Conduct a Readiness Assessment and Gap Analysis

Identify current practices for software inventory, vulnerability tracking, and vendor-provided SBOMs. Map these against CERT-In’s required data fields and formats.

2. Build an Internal SBOM Policy and Governance Structure

Define clear roles for developers, IT operations, procurement, security, and compliance teams. Governance ensures SBOMs are consistently created, maintained, and shared across the enterprise.

3. Select and Implement SBOM Generation Tools

Automation is crucial. Tools must:

  • Generate SBOMs for every new release, patch, or update
  • Integrate with DevOps pipelines, source repositories, and container registries
  • Output in CycloneDX and SPDX formats for regulatory alignment

4. Integrate SBOM Workflows into SDLC and Procurement

Embed SBOM generation at every SDLC stage:

  • Design SBOM: planned components
  • Source SBOM: development dependencies
  • Build SBOM: during compilation
  • Analyzed SBOM: post-build inspection
  • Deployed SBOM: installed environment
  • Runtime SBOM: monitoring active components

Procurement contracts should mandate SBOM delivery from all suppliers.

5. Maintain Ongoing Compliance and Audit Readiness

Establish continuous SBOM updates, integrate with vulnerability advisories like VEX (Vulnerability Exploitability eXchange) and CSAF, and ensure secure storage and sharing through encryption, HTTPS, and digital signatures.

Want to learn how to leverage SBOM for your security strategy?

Accepted SBOM Formats and Technical Standards Under CERT-In

CycloneDX and SPDX: The Accepted Standards

CERT-In recognizes CycloneDX and SPDX as the primary machine-readable formats for SBOM automation.

  • CycloneDX: Lightweight, security-centric, optimized for vulnerability management
  • SPDX: License-focused, widely adopted for compliance documentation

How to Evaluate and Select CERT-In SBOM Compliance Vendors or Solutions

Selecting the right vendor or solution is critical for both compliance and operational efficiency.

Key Criteria for Assessing CERT-In SBOM Compliance Vendors

  • Support for SPDX and CycloneDX
  • Integration with DevOps pipelines and CI/CD workflows
  • Ability to generate multiple SBOM levels (design, build, deployed, runtime)
  • Audit-ready reporting and secure sharing mechanisms

Questions to Ask Potential Vendors About CERT-In Alignment

Selecting the right partners is just as critical as building internal SBOM processes. CIOs and procurement leaders should include CERT-In alignment as part of their RFP and due diligence checklists. Key questions to ask include:

  • Do you provide SBOMs in CERT-In–approved formats (SPDX, CycloneDX)?
  • How often are your SBOMs updated—at release only, or continuously?
  • What automation do you offer for SBOM generation, validation, and secure sharing?
  • How do you enforce secure SBOM distribution (e.g., encryption, RBAC, digital signatures)?
  • Does your solution integrate with DevOps pipelines, vulnerability databases, and CERT-In advisories?
  • How do you support compliance audits and ongoing regulatory reporting?

Asking these questions upfront helps ensure vendors are not only compliant on paper but capable of sustaining SBOM practices that align with CERT-In’s evolving guidelines.

Checklist for Vendor Selection and Onboarding

  • Supports CERT-In’s required data fields and formats
  • Automates generation, tracking, and updates
  • Provides role-based access controls and secure sharing
  • Demonstrated adoption in regulated industries

Best Practices for Seamless SBOM Implementation

Proven Strategies for Large Enterprises

  • Start with foundational workflows and expand maturity over time
  • Mandate SBOM delivery in all procurement contracts
  • Adopt a shift-left approach by integrating SBOM generation early in SDLC
  • Train staff on SBOM awareness and regulatory requirements

Common Mistakes and How to Avoid Them

Even well-intentioned SBOM initiatives can fail if organizations approach them superficially. CERT-In emphasizes that SBOMs must be accurate, comprehensive, and continuously updated. Here are some of the most common pitfalls and how to avoid them:

Common MistakeExplanationHow to Avoid It
Treating SBOM as a static reportMany organizations generate an SBOM at release and never update it. This leaves them blind to vulnerabilities introduced by patches, updates, or new dependencies.Treat the SBOM as a living inventory. Automate updates through your CI/CD pipeline so that every new build or release refreshes the SBOM data.
Failing to include transitive dependenciesOverlooking indirect components, such as open-source libraries pulled in by other dependencies, creates dangerous blind spots that attackers exploit.Use automated SBOM generation tools that recursively map all direct and transitive dependencies, ensuring full coverage across your software supply chain.
Relying on manual creation without automationManual SBOM compilation is time-consuming, error-prone, and unsustainable at enterprise scale. It also increases the risk of inconsistent formats.Integrate automation and standardization. Adopt tools that generate SBOMs in CERT-In–approved formats like SPDX and CycloneDX, and enforce validation before release.

By avoiding these mistakes and embedding SBOM practices into daily development workflows, organizations can turn compliance into a strategic advantage, reducing risk while meeting CERT-In requirements.

Preparing for Audits

Maintain complete SBOM repositories, document governance practices, and align with CERT-In audit templates.

Future-Proofing Against Regulatory Change

CERT-In’s roadmap already hints at broader BOM requirements (hardware, AI, and cloud). Enterprises that adopt scalable, flexible tools will be best positioned to adapt.

Automate, Comply, and Protect: The OPSWAT Approach to SBOM Management

OPSWAT SBOM

OPSWAT SBOM empowers developers by providing an accurate inventory of software components in source code and containers. Stay ahead of attackers, uncover threats, and detect vulnerabilities without impacting development velocity.

SBOM for Software Packages & Artifacts

Enables software development teams to identify, prioritize, and address open-source dependencies' security vulnerabilities and licensing concerns.

SBOM for Software Packages & Artifacts

Enables software development teams to identify, prioritize, and address open-source dependencies' security vulnerabilities and licensing concerns.

SBOM for Container Images

コンテナイメージを分析し、パッケージ名、バージョン情報、潜在的な脆弱性の SBOM を生成します。

MetaDefender Software Supply Chain

Go beyond SBOM compliance and address advanced, evolving software supply chain attacks.

OPSWAT MetaDefender Software Supply Chain provides expanded visibility and a robust defense against supply chain risks. With our zero-trust threat detection and prevention technologies, your software development lifecycle (SDLC) is secured from malware and vulnerabilities, strengthening application security and compliance adherence.

Detect Malware in Code

The combination of 30+ antivirus engines increases detection rates and effectively prevents malware from infecting workstations, containers, or source code.

ハードコードされた秘密を特定する

Proactive DLPTM identifies credentials such as passwords, secrets, tokens, API keys, or other sensitive information left in source code.

Supply Chain 攻撃からコンテナをSecure

コンテナ・イメージの各レイヤーの下に存在するマルウェア、脆弱性、その他の潜在的リスクを評価し、評価する。

シンプルな統合

チームがソースコードリポジトリ、コンテナレジストリ、バイナリサービス、またはそれらのツールの組み合わせを使用しているかどうかに関わらず、MetaDefender Software Supply Chain SDLC全体を通して安全性を確保するために、一般的なプラットフォームとのネイティブな統合を提供します。

よくある質問

What penalties apply for non-compliance with CERT-In SBOM guidelines?

Regulatory audits and potential restrictions on contracts with government and essential services. Non-compliance with CERT-In SBOM guidelines may leave organizations vulnerable to data breaches, which can lead to steep fines.

How often must SBOMs be updated?

At every new release, update, patch, or vendor change.

Can open-source and third-party components be included?

Yes. Complete visibility into all dependencies—direct and transitive—is mandatory.

Are smaller businesses exempt?

Startups outside regulated sectors may have limited relief, but adoption is strongly encouraged.

How does CERT-In align with global standards?

India’s approach mirrors international frameworks like NIST and the EU Cyber Resilience Act, ensuring cross-border compatibility.

How should vulnerability disclosures be handled?

Through VEX and CSAF advisories, integrated with CERT-In alerts and internal SBOM systems.

What role does automation play?

Automation enables continuous compliance, reduces human error, and ensures scalability across hybrid IT environments.

Sector-Specific Considerations: Financial Institutions, Supply Chain, and Critical Infrastructure

金融 

Banks and NBFCs must align SBOM practices with RBI cybersecurity mandates, with stricter audit requirements for sensitive data handling.

Supply Chain

Suppliers must deliver SBOMs as part of contracts. Organizations should maintain internal and external SBOM inventories for transparency and risk management.

重要インフラ

Sectors like telecom, defense, and energy face regulatory overlaps. SBOM practices must integrate with broader frameworks for system resilience and national security.

What’s Next? Preparedness for Cert-In SBOM Guidelines is Essential

The CERT-In SBOM guidelines mark a turning point for Indian enterprises. What began as a narrow focus on SBOMs has now expanded into a comprehensive framework for software supply chain visibility and risk management.

OPSWAT SBOM technology goes beyond compliance, embedding supply chain visibility across the SDLC and integrating multi-layered security with code repositories, container registries, and DevOps pipelines.

Discover how OPSWAT can help your enterprise simplify CERT-In SBOM compliance and secure your software supply chain.

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